in Russia. Where a resident of Russia derives income which, in accordance with the provisions of this Agreement, may be taxed in Singapore, the amount of tax on that income payable in Singapore shall be credited against the tax imposed in Russia. The amount of credit, however, shall not exceed the amount of the tax on that income computed in accordance with the laws and regulations in Russia.
in Russia. (i) in respect of taxes withheld at source for income paid or transferred starting from the first day of January of the calendar year, following the year in which the Agreement enters into force;
(ii) in respect of other taxes, for taxable periods beginning on or after the first day of January of the calendar year, following the year in which the Agreement enters into force.
in Russia. (i) tax on income (profits) of enterprises and organisations; and
(ii) income tax on individuals (in this Agreement referred to as "Russian tax").
in Russia. The Parties acknowledge that the Russian Patent has lapsed and that Curadis has agreed to use its good faith efforts to cause the Russian Patent to be re-instated.
in Russia. Commercial Vehicles, the Appellate Body upheld the Panel's finding that the Russian investigating authority acted inconsistently with Article 4.1 when it excluded one of the producers from the domestic industry on the ground that its data were allegedly deficient. In the course of its analysis, the Appellate Body considered the relationship between Article 4.1 and the "positive evidence" requirement in Article 3.1, and the provisions of Article 6.6, 6.7, and 6.8:
3.1 of the Anti-Dumping Agreement neither permits nor obliges an investigating authority to derogate from defining the domestic industry in relation to the domestic producers of the like product, so as to leave out producers that provided allegedly deficient data. Rather than being permitted or even required by Article 3.1, as Russia seems to argue, the non-inclusion of domestic producers of the like product 31 Appellate Body Report, EC – Fasteners (China) (Article 21.5 – China), para. 5.313. 32 Appellate Body Report, Russia – Commercial Vehicles, paras. 5.28-5.29. 33 Panel Report, Argentina – Poultry Anti-Dumping Duties, para. 7.338. in the domestic industry definition solely on the basis that they furnished allegedly deficient information is incompatible with the requirements of this provision. This is because, if an investigating authority were permitted to leave out, from the definition of domestic industry, domestic producers of the like product that provided allegedly deficient information, a material risk of distortion would arise in the injury analysis. The non-inclusion of this category of producers could make the domestic industry definition no longer representative of the total domestic production, thereby undermining the accuracy of the injury analysis. Rather than leaving a producer of the like product that provided allegedly deficient information out of the domestic industry, the investigating authority should seek to obtain additional information from that domestic producer. In this respect, Article 6.6 of the Anti-Dumping Agreement provides that investigating authorities shall, 'during the course of an investigation', satisfy themselves as to the accuracy of the information supplied. Article 6.7 of the Anti-Dumping Agreement sets out additional actions that authorities may take to verify information provided or to obtain further details. Article 6.8 of the Anti-Dumping Agreement allows investigating authorities to make determinations on the basis of facts available in cases where a...
in Russia. (i) in respect of tax withheld at source, for amounts paid or credited on or after the first day of January in the calendar year next following that in which the Convention enters into force and subsequent years; and
(ii) in respect of other taxes on income and on capital, for taxation years beginning on or after the first day of January in the calendar year next following that in which the Convention enters into force and subsequent years.
in Russia. All disputes in relation to the interpretation, the violation, the termination, or the nullity of the execution of this Agreement shall be settled by Arbitration Court of Moscow; and
in Russia. Commercial Vehicles, the Appellate Body concluded that the Panel did not err in finding that the Russian investigating authority acted inconsistently with Article 4.1, and consequently Article 3.1, when it excluded one of the producers from the domestic industry on the ground that its data were allegedly deficient. In response to Russia's argument that this finding would render the "major proportion" requirement in Article 4.1 inutile, the Appellate Body stated: "[W]e recall that the Appellate Body has recognized the difficulty of obtaining information regarding domestic producers in certain situations, such as fragmented industries with numerous producers. In such special cases, the term 'major proportion' in Article 4.1 allows an investigating authority a certain degree of flexibility in defining the domestic industry. Nevertheless, an investigating authority continues to bear the obligation to ensure that the way in which it defines the domestic industry does not introduce a material risk of distortion into the injury analysis. In our view, the situation where an investigating authority is unable to collect any information at all from every domestic producer due to the fragmented nature of the industry is different from the situation where a domestic producer sought to cooperate in the investigation and did submit information that the investigating authority, however, considered to be deficient. We consider that the Panel correctly recognized that an investigating authority could define the domestic industry as a 'major proportion' of the total domestic production as long as both the quantitative and qualitative elements are satisfied. The Panel also correctly found that Article 4.1 does not allow an investigating authority to leave out of the definition of domestic industry the domestic producers of the like product that provided allegedly deficient information. Thus, contrary to Russia's claim on appeal, we do not consider that the Panel's interpretation of Article 4.1 of the Anti-Dumping Agreement reduces the term 'major proportion' in this provision to inutility."32
in Russia. Where a resident of Russia derives income or owns capital which, in accordance with the provisions of this Convention is taxed in Spain, the amount of tax payable in Spain on that income or capital shall be credited against the tax imposed in Russia. The amount of credit, however, shall not exceed the amount of the tax on that income or capital computed in accordance with the laws and regulations of Russia.
in Russia. All disputes will be settled by the Arbitrazh Court of Moscow. All disputes arising out of this Agreement shall be finally settled by the London Court of International Arbitration (LCIA) (Arbitration Body), under the LCIA Arbitration Rules (the Rules), in London, UK, with English as the official language, by three impartial arbitrators appointed in accordance with the Rules. Each party will nominate one arbitrator, who will jointly appoint an independent chairman within 30 days or else the chairman will be appointed by the Arbitration Body under the Rules. The arbitrators will have no authority to award injunctive relief or damages excluded by or exceeding limits in this Agreement. Nothing in this Agreement will prevent either party from resorting to judicial proceedings for (1) interim relief to prevent material prejudice or a breach of confidentiality provisions or intellectual property rights, or (2) determining the validity or ownership of any copyright, patent or trademark owned or asserted by a party or its Enterprise company, or (3) debt collection in amounts below USD 500.000,00. All disputes arising out of this Agreement shall be finally settled by the ICC International Court of Arbitration, in Paris (Arbitration Body), under its arbitration rules (the Rules), in Paris, France, with French as the official language, by three impartial arbitrators appointed in accordance with the Rules. Each party will nominate one arbitrator, who will jointly appoint an independent chairman within 30 days or else the chairman will be appointed by the Arbitration Body under the Rules. The arbitrators will have no authority to award injunctive relief or damages excluded by or exceeding limits in this Agreement. Nothing in this Agreement will prevent either party from resorting to judicial proceedings for (1) interim relief to prevent material prejudice or a breach of confidentiality provisions or intellectual property rights, or (2) determining the validity or ownership of any copyright, patent or trademark owned or asserted by a party or its Enterprise company, or (3) debt collection in amounts below USD 250.000,00. All disputes arising out of this Agreement shall be finally settled by the Arbitration Foundation of Southern Africa (AFSA) (Arbitration Body), under the Rules of the Arbitration of the AFSA (the Rules), in Johannesburg, South Africa, with English as the official language, by three impartial arbitrators appointed in accordance with the Rules. Each party ...
